Hazardous Communications
Standard
Revised 2013
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OSHA SAYS
•
Workers have the right to know and understand the
hazardous chemicals they use and how to work with them
safely.
• Thus, it created the Hazardous Communications standard.
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The new HazCom standard
OSHA has adopted new hazardous chemical labeling requirements
as a part of its recent revision of the Hazard Communication
Standard, 29 CFR 1910.1200 (HCS), bringing it into alignment with
the United Nations’ Globally Harmonized System of Classification
and Labeling of Chemicals (GHS).
These changes will help ensure improved quality and consistency in
the classification and labeling of all chemicals, and will also enhance
worker comprehension. As a result, workers will have better
information available on the safe handling and use of hazardous
chemicals, thereby allowing them to avoid injuries and illnesses
related to exposures to hazardous chemicals.
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The new standard
The revised standard requires that information about chemical
hazards be conveyed on labels using quick visual notations to
alert the user, providing immediate recognition of the hazards.
Labels must also provide instructions on how to handle the
chemical so that chemical users are informed about how to
protect themselves.
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Overview
•
The label provides information to the workers on the specific
hazardous chemical.
• While labels provide important information for anyone who
handles, uses, stores, and transports hazardous chemicals,
they are limited by design in the amount of information they
can provide.
• Safety Data Sheets (SDSs), which must accompany hazardous
chemicals, are the more complete resource for details
regarding hazardous chemicals.
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overview
•
The revised standard requires the use of a 16-section safety
data sheet format, which provides detailed information
regarding the chemical.
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Implementation
• All hazardous chemicals shipped after June 1, 2015, must be
labeled with specified elements including pictograms, signal
words and hazard and precautionary statements.
• You will start to see these labels prior to that, however.
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Product Identifiers
• Employees, volunteers and emergency responders must be
able to identify the hazardous chemicals using these
identifiers.
• Identifiers could include:
– Chemical name, code and batch number
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Labels
• Labels, as defined in the new standard, are an appropriate
group of written, printed or graphic informational elements
concerning a hazardous chemical that are affixed to, printed
on, or attached to the immediate container of a hazardous
chemical, or to the outside packaging.
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Labels, continued
• The HazCom Standard requires chemical manufacturers,
importers, or distributors to ensure that each container of
hazardous chemicals leaving the workplace is labeled, tagged
or marked with the following information:
– product identifier;
– signal word;
– hazard statement(s);
– Precautionary statement
– pictogram(s);
– and name, address and telephone number of the chemical
manufacturer, importer, or other responsible party.
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Label Elements
• Name, Address and Telephone Number of the chemical
manufacturer, importer or other responsible party.
• Product Identifier is how the hazardous chemical is identified.
This can be (but is not limited to) the chemical name, code
number or batch number. The manufacturer, importer or
distributor can decide the appropriate product identifier. The
same product identifier must be both on the label and in
section 1 of the SDS.
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Label Elements: Signal Words
• Signal Words are used to indicate the relative level of severity
of the hazard and alert the reader to a potential hazard on the
label.
• There are only two words used as signal words, “Danger” and
“Warning.” Within a specific hazard class, “Danger” is used for
the more severe hazards and “Warning” is used for the less
severe hazards.
• There will only be one signal word on the label no matter how
many hazards a chemical may have. If one of the hazards
warrants a “Danger” signal word and another warrants the
signal word “Warning,” then only “Danger” should appear on
the label.
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Label Elements: Pictograms
• OSHA’s required pictograms must be in the shape of a square
set at a point and include a black hazard symbol on a white
background with a red frame sufficiently wide enough to be
clearly visible.
• OSHA has designated eight pictograms under this standard for
application to a hazard category.
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Label Elements: Hazard Statements
• H.E.’s Describe the nature of the hazard(s) of a chemical,
including, where appropriate, the degree of hazard.
– For example: “Causes damage to kidneys through prolonged
or repeated exposure when absorbed through the skin.”
• All of the applicable hazard statements must appear on the
label.
• Hazard statements may be combined where appropriate to
reduce redundancies and improve readability.
• The hazard statements are specific to the hazard classification
categories, and chemical users should always see the same
statement for the same hazards, no matter what the chemical is
or who produces it.
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Hazard Statements
• For example, a chemical presenting a specific target organ
toxicity (repeated exposure) hazard would include the
following on the label:
“Do not breathe dust/fume/gas/mist/vapors/spray. Get
medical advice/attention if you feel unwell. Dispose of
contents/container in accordance with local/regional/
national and international regulations.”
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Label Elements:
Precautionary Statement
• Describe recommended measures that should be taken to
minimize or prevent adverse effects resulting from exposure
to the hazardous chemical or improper storage or handling.
• There are four types of precautionary statements:
– prevention (to minimize exposure);
– response (in case of accidental spillage or exposure
emergency response, and first-aid);
– storage;
– disposal.
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Label Elements:
Precautionary Statements
• Precautionary statements may be combined on the label to save on
space and improve readability. For example, “Keep away from heat,
spark and open flames,” “Store in a well-ventilated place,” and
“Keep cool” may be combined to read: “Keep away from heat,
sparks and open flames and store in a cool, well-ventilated place.”
• Where a chemical is classified for a number of hazards and the
precautionary statements are similar, the most stringent statements
must be included on the label. In this case, the chemical
manufacturer, importer, or distributor may impose an order of
precedence where phrases concerning response require rapid
action to ensure the health and safety of the exposed person.
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Supplemental information
• Must list: Name, address and phone number of the chemical
manufacturer, distributor, or importer.
• The label producer may provide additional instructions or
information that it deems helpful. It may also list any hazards not
otherwise classified under this portion of the label. This section
must also identify the percentage of ingredient(s) of unknown
acute toxicity when it is present in a concentration of ≥1% (and
the classification is not based on testing the mixture as a whole).
• There is also no required format for how a workplace label must
look and no particular format an employer has to use; however, it
cannot contradict or detract from the required information.
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Pictograms
• Pictograms are graphic symbols used to communicate specific
information about the hazards of a chemical.
• On hazardous chemicals being shipped or transported from a
manufacturer, importer or distributor, the required
pictograms consist of a red square frame set at a point with a
black hazard symbol on a white background, sufficiently wide
to be clearly visible.
• A square red frame set at a point without a hazard symbol is
not a pictogram and is not permitted on the label.
• The pictograms OSHA has adopted improve worker safety and
health, conform with the GHS, and are used worldwide.
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Please note:
• The OSHA pictograms do not replace the diamond-shaped
labels that the U.S. Department of Transportation (DOT)
requires for the transport of chemicals, including chemical
drums, chemical totes, tanks or other containers.
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Employer Obligations
• Employers are responsible for maintaining the labels on the
containers, including, but not limited to, tanks, totes, and drums.
This means that labels must be maintained on chemicals in a
manner which continues to be legible and the pertinent
information does not get defaced or removed in any way.
• The employer is not responsible for updating labels on shipped
containers, even if the shipped containers are labeled under
HazCom 1994. The employer must re-label items if the labels are
removed or defaced. However, if the employer is aware of newlyidentified hazards that are not disclosed on the label, the
employer must ensure that the workers are aware of the hazards
as discussed below under workplace labels.
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Sample Label
Pictogram
Hazard
Statement
Precautionary
Statement
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How might an employee use the labels
in the workplace?
✓ Explain how information on the label can be
used to ensure proper storage of hazardous
chemicals.
✓ Explain how the information on the label
might be used to quickly locate information on
first aid when needed by employees or
emergency personnel.
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Questions?
Pinsky Law Group
5789 Widewaters Parkway
Syracuse, New York 13214
(315) 428-8345
Brad@pinskylaw.com
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